Welcome to our CSRD Gap Tool

You shall disclose the following:

a. whether your sustainability statement has been prepared on a consolidated or individual basis

b. for consolidated sustainability statements:

i. a confirmation that the scope of consolidation is the same as for the financial statements, or, where applicable, a declaration that you are not required to draw-up financial statements or that you are preparing consolidated sustainability reporting pursuant to Article 48i of Directive 2013/34/EU

ii. where applicable, an indication of which of your subsidiary undertakings included in the consolidation that are exempted from individual or consolidated sustainability reporting pursuant to Articles 19a(9) or 29a(8) of Directive 2013/34/EU

c. to what extent your sustainability statement covers your upstream and downstream value chain

d. whether you have used the option to omit a specific piece of information corresponding to intellectual property, know-how or the results of innovation

e. if you are based in an EU member state that allows for the exemption from disclosure of impending developments or matters in the course of negotiation, as provided for in articles 19a(3) and 29a(3) of Directive 2013/34/EU, whether you have used that exemption.

Click here to read the full Discloure Requirement

You may report this information alongside the disclosures to which they refer.

Specific circumstances refers to the following:

Time horizons 

When you have deviated from definitions of short-term (same as reporting period), medium-term (<5 years),  or long-term (5+years) time horizons, you shall describe:

a. your definitions of medium- or long-term time horizons

b. the reasons for applying those definitions

Value chain estimation

When metrics include upstream and/or downstream value chain data estimated using indirect sources, such as sector-average data or other proxies, you shall:

a. identify the metrics

b. describe the basis for preparation

c. describe the resulting level of accuracy

d. where applicable, describe the planned actions to improve the accuracy in the future

Sources of estimation and outcome uncertainty

In accordance with ESRS 1 section 7.2 Sources of estimation and outcome uncertainty, you shall:

a. identify the quantitative metrics and monetary amounts you have disclosed that are subject to a high level of measurement uncertainty

b. in relation to each quantitative metric and monetary amount identified:

i. disclose information about the sources of measurement uncertainty (for example, the dependence of the amount on the outcome of a future event, on a measurement technique or on the availability and quality of data from your upstream and/or downstream value chain)

ii. disclose the assumptions, approximations and judgements you have made in measuring it

When disclosing forward-looking information, you may indicate that you consider such information to be uncertain

Changes in preparation or presentation of sustainability information

When changes in the preparation and presentation of sustainability information occur compared to the previous reporting period(s) you shall:

a. explain the changes and the reasons for them, including why the replaced metric provides more useful information

b. disclose revised comparative figures, unless it is impracticable to do so. When it is impracticable to adjust comparative information for one or more prior periods, you shall disclose that fact

c. disclose the difference between the figure disclosed in the preceding period and the revised comparative figure

Reporting errors in prior periods

When you identify material prior period errors you shall disclose:

a. the nature of the prior period material error

b. to the extent practicable, the correction for each prior period included in the sustainability statement

c. if correction of the error is not practicable, the circumstances that led to the existence of that condition

Disclosures stemming from other legislation or generally accepted sustainability reporting pronouncements

When you include in your sustainability statement information stemming from other legislation which requires you to disclose sustainability information from other generally accepted sustainability reporting standards and frameworks, in addition to the information prescribed by ESRS, you shall disclose this fact. In case of partial application of other reporting standards or frameworks, you shall provide a precise reference to the paragraphs of the standard or framework applied.

Incorporation by reference

When you incorporate information by reference, you shall disclose a list of the disclosure requirements of ESRS, or the specific datapoints mandated by a Disclosure Requirement, that have been incorporated by reference.

Use of phase-In provisions in accordance with Appendix C of ESRS 1

If you do not exceed on your balance sheet date the average number of 750 employees during the financial year you can during the first or the first 2 years of preparation of your sustainability statement decide to omit information required by: 

- ESRS E4 (can be omitted during the first 2 years)

- ESRS S1 (can be omitted during the first year)

- ESRS S2 (can be omitted during the first 2 years)

- ESRS S3 (can be omitted during the first 2 years)

- ESRS S4 (can be omitted during the first 2 years)

However, if deciding to do so you shall nevertheless disclose whether the sustainability topics covered by each respective standard have been assessed to be material as a result of your materiality assessment. Additionally, if one or more of these topics have been assessed to be material, you shall for each material topic:

a. disclose the list of matters in AR 16 ESRS 1 Appendix A that are assessed to be material and briefly describe how your business model and strategy take into account your organizations’ impacts related to those matters. You may identify these matters at the level of topic, sub-topic or sub-sub-topic.

b. briefly describe any time-bound targets you have set related to the matters in question, the progress you have made towards achieving those targets, and whether your targets related to biodiversity and ecosystems are based on conclusive scientific evidence 

c. briefly describe your policies in relation to the matters in question

d. briefly describe actions you have taken to identify, monitor, prevent, mitigate, remediate or bring an end to actual or potential adverse impacts related to the matters in question, and the result of such actions

e. disclose metrics relevant to the matters in question

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You shall disclose the following information about the composition and diversity of the members of your administrative, management and supervisory bodies:

a. the number of executive and non-executive members

b. representation of employees and other workers

c. experience relevant to the sectors, products and geographic locations of your organization

d. percentage by gender and other aspects of diversity that your organization considers relevant

e. the percentage of independent board members

You shall disclose the following information about the roles and responsibilities of the administrative, management and supervisory bodies:

a. the identity of the administrative, management and supervisory bodies (such as a board committee or similar) or individual(s) within a body responsible for oversight of impacts, risks and opportunities

b. how each body’s or individual’s responsibilities for impacts, risks and opportunities are reflected in your terms of reference, board mandates and other related policies

c. a description of management’s role in the governance processes, controls and procedures used to monitor, manage and oversee impacts, risks and opportunities, including:

i. whether that role is delegated to a specific management-level position or committee and how oversight is exercised over that position or committee

ii. information about the reporting lines to the administrative, management and supervisory bodies

iii. whether dedicated controls and procedures are applied to the management of impacts, risks and opportunities and, if so, how they are integrated with other internal functions

d. how the administrative, management and supervisory bodies and senior executive management oversee the setting of targets related to material impacts, risks and opportunities, and how they monitor progress towards them

This disclosure shall also include a description of how the administrative, management and supervisory bodies determine whether appropriate skills and expertise are available or will be developed to oversee sustainability matters, including:

a. the sustainability-related expertise that the bodies, as a whole, either directly possess or can leverage, for example through access to experts or training

b. how those skills and expertise relate to your organization’s material impacts, risks and opportunities

Please note, some datapoints in topical standard G1 Governance/Business conduct relate to GOV-1 and refer back to this disclosure requirement, and these should be reported alongside GOV-1.

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According to this disclosure requirement you shall disclose the following:

a. whether, by whom and how frequently the administrative, management and supervisory bodies, including their relevant committees, are informed about:

i. material impacts, risks and opportunities

ii. the implementation of due diligence

iii. the results and effectiveness of policies, actions, metrics and targets adopted to address material impacts, risks and opportunities

b. how the administrative, management and supervisory bodies consider impacts, risks and opportunities when overseeing your organization’s strategy, your decisions on major transactions and your risk management process

c. a list of the material impacts, risks and opportunities addressed by the administrative, management and supervisory bodies, or their relevant committees during the reporting period

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You shall disclose the following information about the incentive schemes and remuneration policies linked to sustainability matters for members of your administrative, management and supervisory bodies, where they exist:

a. a description of the key characteristics of the incentive schemes

b. whether performance is being assessed against specific sustainability-related targets and/or impacts, and if so, which ones

c. whether and how sustainability-related performance metrics are considered as performance benchmarks or included in remuneration policies

d. the proportion of variable remuneration dependent on sustainability-related targets and/or impacts

e. at which level in your organization the terms of incentive schemes are approved and updated

Please note, some datapoints in topical standard E1 Climate change relate to GOV-3 and refer back to this disclosure requirement, and these should be reported alongside GOV-3.

Click here to read the full Discloure Requirement

You shall provide a mapping that explains how and where your application of the main aspects and steps of the due diligence process are reflected in your sustainability statement, to allow a depiction of the actual practices of your organization with regard to due diligence.

This disclosure requirement does not mandate any specific behavioural requirements with regard to due diligence actions and does not extend or modify the role of administrative, management and supervisory bodies as mandated by other legislation or regulation.

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According to this disclosure requirement you shall disclose the following information:

a. the scope, main features and components of your risk management and internal control processes and systems in relation to sustainability reporting

b. the risk assessment approach followed, including the risk prioritisation methodology

c. the main risks identified and their mitigation strategies including related controls

d. a description of how you integrate the findings of your risk assessment and internal controls regarding the sustainability reporting process into relevant internal functions and processes

e. a description of the periodic reporting of the findings referred to in point (d) to the administrative, management and supervisory bodies

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You shall disclose the following information about the key elements of your general strategy that relate to or affect sustainability matters:

a. a description of:

i. significant groups of products and/or services offered

ii. significant markets and/or customer groups served

iii. headcount of employees by geographical areas

iv. where applicable and material, products and services that are banned in certain markets

b. a breakdown of total revenue, as included in your financial statements, by significant ESRS sectors

c. a list of the additional significant ESRS sectors beyond the ones reflected under point (b), such as activities that give rise to intercompany revenues, in which you develop significant activities, or in which you are or may be connected to material impacts

d. where applicable, a statement indicating, together with the related revenues, that your organization is active in:

i. the fossil fuel (coal, oil and gas) sector

ii. chemicals production

iii. controversial weapons

iv. the cultivation and production of tobacco

e. your sustainability-related goals in terms of significant groups of products and services, customer categories, geographical areas and relationships with stakeholders

f.  an assessment of your current significant products and/or services, and significant markets and customer groups, in relation to your sustainability-related goals

g. the elements of your strategy that relate to or impact sustainability matters, including the main challenges ahead, critical solutions or projects to be put in place

Furthermore, you shall disclose a description of your business model and value chain, including:

a. your inputs and your approach to gathering, developing and securing those inputs

b. your outputs and outcomes in terms of current and expected benefits for customers, investors and other stakeholders

c. the main features of your upstream and downstream value chain and the position of your organization in your value chain, including a description of the main business actors (such as key suppliers, customers, distribution channels and end-users) and their relationship to your organization

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You shall disclose a summarised description of

a. your stakeholder engagement, including:

i. your key stakeholders;

ii. whether engagement with them occurs and for which categories of stakeholders

iii. how it is organised

iv. its purpose

v. how its outcome is taken into account by your organization

b. your understanding of how the interests and views of your key stakeholders relate to your strategy and business model, and to what extent these were analysed during your due diligence process and/or materiality assessment process.

c.  where applicable, amendments to your strategy and/or business model, including:

i. how you have amended or expect to amend your strategy and/or business model to address the interests and views of your stakeholders

ii. any further steps that are being planned and in what timeline

iii. whether these steps are likely to modify the relationship with and views of stakeholders

d. whether and how the administrative, management and supervisory bodies are informed about the views and interests of affected stakeholders with regard to your sustainability-related impacts

Please note, some datapoints in certain topical standards relate to SBM-2 and refer back to this disclosure requirement, and these should be reported alongside SBM-2:

S1 Own workforce

S2 Value chain workers

S3 Affected communities

S4 Consumers and end-users

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According to this disclosure requirement you shall disclose the following:

a. a brief description of your material impacts, risks and opportunities resulting from your materiality assessment, including a description of where in your business model, your own operations and your upstream and downstream value chain these material impacts, risks and opportunities are concentrated

b. the current and anticipated effects of your material impacts, risks and opportunities on your business model, value chain, strategy and decision-making, and how you have responded or plan to respond to these effects, including any changes you have made or plan to make to your strategy or business model as part of your actions to address particular material impacts or risks, or to pursue particular material opportunities with reference to your material impacts:

i. how your material negative and positive impacts affect (or, in the case of potential impacts, are likely to affect) people or the environment

ii. whether and how the impacts originate from or are connected to your strategy and business model

iii. the reasonably expected time horizons of the impacts

iv. whether you are involved with the material impacts through your activities or because of your business relationships, describing the nature of the activities or business relationships concerned

d. the current financial effects of your material risks and opportunities on your financial position, financial performance and cash flows and the material risks and opportunities for which there is a significant risk of a material adjustment within the next annual reporting period to the carrying amounts of assets and liabilities reported in your related financial statements

e. the anticipated financial effects on your material risks and opportunities on your financial position, financial performance and cash flows over the short-, medium- and long-term, including the reasonably expected time horizons for those effects. This shall include how you expect your financial position, financial performance and cash flows to change over the short, medium- and long-term, given your strategy to manage risks and opportunities, taking into consideration:

i. your investment and disposal plans (for example, capital expenditure, major acquisitions and divestments, joint ventures, business transformation, innovation, new business areas and asset retirements), including plans you are not contractually committed to

ii. your planned sources of funding to implement your strategy

f. information about the resilience of your strategy and business model regarding your capacity to address your material impacts and risks and to take advantage of your material opportunities. You shall disclose a qualitative and, when applicable, a quantitative analysis of the resilience, including how the analysis was conducted and the time horizons that were applied as defined in ESRS 1. When providing quantitative information, you may disclose single amounts or ranges.

g. changes to the material impacts, risks and opportunities compared to the previous reporting period

h. a specification of those impacts, risks and opportunities that are covered by ESRS Disclosure Requirements as opposed to those covered by your organization using additional entity-specific disclosures

Please note, some datapoints in certain topical standards relate to SBM-3 and refer back to this disclosure requirement, and these should be reported alongside SBM-3:

E1 Climate change

E4 Biodiversity and ecosystems

S1 Own workforce

S2 Value chain workers

S3 Affected communities

S4 Consumers and end-users

Click here to read the full Discloure Requirement

You shall disclose the following information:

a. a description of the methodologies and assumptions applied in the described process

b. an overview of the process to identify, assess, prioritise and monitor your potential and actual impacts on people and the environment, informed by your due diligence process, including an explanation of whether and how the process:

i. focusses on specific activities, business relationships, geographies or other factors that give rise to heightened risk of adverse impacts

ii. considers the impacts with which your organization is involved through your own operations or as a result of your business relationships

iii. includes consultation with affected stakeholders to understand how they may be impacted, and with external experts

iv. how you prioritise negative impacts based on their relative severity and likelihood, and, if applicable, positive impacts on their relative scale, scope and likelihood, and how you determine which sustainability matters are material for reporting purposes, including the qualitative or quantitative thresholds and other criteria used as prescribed by ESRS 1

c. an overview of the process used to identify, assess, prioritise and monitor risks and opportunities that have or may have financial effects. This shall include:

i. how you have considered the connections of your impacts and dependencies with the risks and opportunities that may arise from those impacts and dependencies

ii. how you assess the likelihood, magnitude, and nature of effects of the identified risk and opportunities (such as the qualitative or quantitative thresholds and other criteria used as prescribed by ESRS 1)

iii. how you prioritise sustainability-related risks relative to other types of risks, including your use of risk-assessment tools

d. a description of your decision-making process and the related internal control procedures

e. the extent to which and how the process to identify, assess and manage impacts and risks is integrated into your overall risk management process and used to evaluate your overall risk profile and risk management processes

f. the extent to which and how the process to identify, assess and manage opportunities is integrated into your overall management process where applicable

g. the input parameters you use (for example, data sources, the scope of operations covered and the detail used in assumptions)

h. whether and how the process has changed compared to the prior reporting period, when the process was modified for the last time and future revision dates of the materiality assessment

Please note, some datapoints in certain topical standards relate to IRO-1 and refer back to this disclosure requirement, and these should be reported alongside IRO-1:

E1 Climate change

E2 Pollution

E3 Water and marine resources

E4 Biodiversity and ecosystems

E5 Resource use and circular economy

S1 Own workforce

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You shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of your materiality assessment, including the page numbers and/or paragraphs where the related disclosures are located in your sustainability statement. This may be presented as a content index. 

You shall also include a table of all the datapoints that derive from other EU legislation, indicating where they can be found in you sustainability statement, including those that your have assessed as not material.

If you conclude that climate change is not material and therefore omit all Disclosure Requirements in ESRS E1 Climate change, you shall disclose a detailed explanation of the conclusions of your materiality assessment with regard to climate change, including a forward-looking analysis of the conditions that could lead to you concluding that climate change is material in the future.

If you conclude that a topic other than climate change is not material and therefore omit all the Disclosure Requirements in the corresponding topical ESRS, you may provide a brief explanation of the conclusions of your materiality assessment for that topic.

You shall provide an explanation of how you have determined the material information to be disclosed in relation to the impacts, risks and opportunities that you have assessed to be material, including the use of thresholds and/or how you have implemented the criteria in ESRS 1 section 3.2 Material matters and materiality of information.

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Your transition plan for climate change mitigation should include: 

a. by reference to your GHG emission reduction targets an explanation of how your targets are compatible with the limiting of global warming to 1.5°C in line with the Paris Agreement

b. by reference to your GHG emission reduction targets and your climate change mitigation actions, an explanation of the decarbonisation levers you have identified and your key actions planned, including changes in your product and service portfolio and the adoption of new technologies in your own operations, or in your upstream and/or downstream value chain

c. by reference to your climate change mitigation actions, an explanation and quantification of your investments and funding supporting the implementation of your transition plan, with a reference to your key performance indicators of taxonomy-aligned CapEx, and where relevant the CapEx plans, that you disclose in accordance with Commission Delegated Regulation (EU) 2021/2178

d. a qualitative assessment of the potential locked-in GHG emissions from your key assets and products. This shall include an explanation of if and how these emissions may jeopardise the achievement of your GHG emission reduction targets and drive transition risk, and if applicable, an explanation of your plans to manage your GHG-intensive and energy intensive assets and products

e. if you have economic activities that are covered by delegated regulations on climate adaptation or mitigation under the Taxonomy Regulation, an explanation of any objective or plans (CapEX, CapEx plans, OpEX) that you have for aligning your economic activities (revenues, CapEx, OpEx) with the criteria established in Commission Delegated Regulation 2021/2139

f. if applicable, a disclosure of significant CapEx amounts invested during the reporting period related to coal, oil and gas-related economic activities

g. a disclosure on whether or not your organization is excluded from the EU Paris-aligned Benchmarks

h. an explanation of how the transition plan is embedded in and aligned with your overall business strategy and financial planning

i. whether the transition plan is approved by the administrative, management and supervisory bodies

j. an explanation of your progress in implementing your transition plan

In case you do not have a transition plan in place, you shall indicate whether and, if so, when you will adopt a transition plan.

Furthermore, you shall explain for each material climate-related risk you have identified, whether you consider the risk to be a climate-related physical risk or climate-related transition risk, and describe the resilience of your strategy and business model in relation to climate change. This description shall include:

a. the scope of the resilience analysis

b. how and when the resilience analysis has been conducted, including the use of climate scenario analysis as referenced in the Disclosure Requirement related to ESRS 2 IRO-1 and the related application requirement paragraphs

c. the results of the resilience analysis including the results from the use of scenario analysis

Lastly, you shall describe your process to identify and assess climate-related impacts, risks and opportunities. This description shall include your process in relation to:

a. impacts on climate change, in particular, your GHG emissions

b. climate-related physical risks in your own operations and along your upstream and downstream value chain, in particular:

i. the identification of climate-related hazards, considering at least high emission climate scenarios

ii. the assessment of how your assets and business activities may be exposed and are sensitive to these climate-related hazards, creating gross physical risks for your organization

c. climate-related transition risks and opportunities in your own operations and along your upstream and downstream value chain, in particular:

i. the identification of climate-related transition events, considering at least a climate scenario in line with limiting global warming to 1.5°C with no or limited overshoot

ii. the assessment of how your assets and business activities may be exposed to these climate-related transition events, creating gross transition risks or opportunities for your organization

When disclosing this information you shall explain how you have used climate-related scenario analysis, including a range of climate scenarios, to inform the identification and assessment of physical risks and transition risks and opportunities over the short-, medium- and long-term.

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Specifically, your policies related to climate change mitigation and climate change adaptation shall address the following areas:

a. climate change mitigation

b. climate change adaptation

c. energy efficiency

d. renewable energy deployment 

e. other

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information:

a. a description of the key contents of your policy related to climate change mitigation and climate change adaptation, including its general objectives and which material impacts, risks or opportunities the policy relates to and the process for monitoring

b. a description of the scope of the policy, or of its exclusions, in terms of activities, upstream and/or downstream value chain, geographies and if relevant, affected stakeholder groups

c. the most senior level in your organisation that is accountable for the implementation of the policy

d. a reference, if relevant, to the third-party standards or initiatives your organization commit to respect through the implementation of the policy

e. if relevant, a description of the consideration given to the interests of key stakeholders in setting the policy

f. if relevant, whether and how you make the policy available to potentially affected stakeholders, and stakeholders who need to help implement it

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When disclosing your action related climate change mitigation and climate change adaptation you shall provide the following information:

a. your key actions taken in the reporting year and your key actions planned for the future

b. present your climate change mitigation actions by decarbonisation lever including nature-based solutions

c. your achieved and expected GHG emission reductions

d. relate significant monetary amounts of CapEx and OpEx required to implement the actions taken or planned to:

i. the relevant line items or notes in the financial statements

ii. the key performance indicators required under Commission Delegated Regulation (EU) 2021/2178

iii. if applicable, the CapEx plan required by Commission Delegated Regulation (EU) 2021/2178

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information:

a. the list of key actions taken in the reporting year and planned for the future, their expected outcomes and, where relevant, how their implementation contributes to the achievement of policy objectives and targets

b. the scope of the key actions (i.e., coverage in terms of activities, upstream and/or downstream value chain, geographies and, where applicable, affected stakeholder groups)

c. the time horizons under which you intend to complete each key action

d. if applicable, key actions taken (along with results) to provide for and cooperate in or support the provision of remedy for those harmed by actual material impacts

e. if applicable, quantitative and qualitative information regarding the progress of actions or action plans disclosed in prior periods

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You shall disclose:

a. Whether and how you have set GHG emissions reduction targets

b. Any other targets to manage material climate-related impacts, for example targets related to:

i. renewable energy deployment

ii. energy efficiency

iii. climate change adaptation

iv. physical or transition risk mitigation

If you have set GHG emission reduction targets, the following requirements apply:

a. GHG emission reduction targets shall be disclosed in absolute value (either in tonnes of CO2eq or as a percentage of the emissions of a base year) and, where relevant, in intensity value

b. GHG emission reduction targets shall be disclosed for Scope 1, 2, and 3 GHG emissions, either separately or combined, and:

i. in case of combined GHG emission reduction targets, you shall specify which GHG emission Scopes (1, 2 and/or 3) are covered by the target, the share related to each respective GHG emission Scope and which GHGs are covered

ii. you shall also explain how the consistency of these targets with your GHG inventory boundaries is ensured

iii. The GHG emission reduction targets shall be gross targets, meaning that your shall not include GHG removals, carbon credits or avoided emissions as a means of achieving your GHG emission reduction targets

c. You shall disclose your current base year and baseline value, and from 2030 onwards, update the base year for your GHG emission reduction targets after every five year period thereafter. You may disclose the past progress made in meeting your targets before your current base year provided that this information is consistent with the requirements of this ESRS standard

d. GHG emission reduction targets shall at least include target values for the year 2030 and, if available, for the year 2050. From 2030, target values shall be set after every 5-year period thereafter

e. you shall state whether the GHG emission reduction targets are science-based and compatible with limiting global warming to 1.5°C, and:

i. You shall state which framework and methodology has been used to determine these targets including whether they are derived using a sectoral decarbonisation pathway and what the underlying climate and policy scenarios are and whether your targets have been externally assured

ii. As part of the critical assumptions for setting GHG emission reduction targets, you shall briefly explain how you have considered future developments (e.g., changes in sales volumes, shifts in customer preferences and demand, regulatory factors, and new technologies) and how these will potentially impact both your GHG emissions and emissions reductions

f. you shall describe the expected decarbonisation levers and their overall quantitative contributions to achieve your GHG emission reduction targets (e.g., energy or material efficiency and consumption reduction, fuel switching, use of renewable energy, phase out or substitution of product and process).

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information for each measurable, outcome-oriented and time-bound target on material sustainability matters that you have set:

a. a description of the relationship of the target to the policy objectives 

b. the defined target level to be achieved, including, where applicable, whether the target is absolute or relative and in which unit it is measured

c. the scope of the target, including your own activities and/or your upstream and/or downstream value chain where applicable and geographical boundaries

d. the baseline value and base year from which progress is measured

e. the period to which the target applies and if applicable, any milestones or interim targets

f. the methodologies and significant assumptions used to define targets, including where applicable, the selected scenario, data sources, alignment with national, EU or international policy goals and how the targets consider the wider context of sustainable development and/or local situation in which impacts take place

g. whether your targets related to environmental matters are based on conclusive scientific evidence

h. whether and how stakeholders have been involved in target setting for each material sustainability matter

i. any changes in targets and corresponding metrics or underlying measurement methodologies, significant assumptions, limitations, sources and processes to collect data adopted within the defined time horizon. This includes an explanation of the rationale for those changes and their effect on comparability

j. the performance against your disclosed targets, including information on how the target is monitored and reviewed and the metrics used, whether the progress is in line with what had been initially planned, and an analysis of trends or significant changes in the performance of your organization towards achieving the target

If you have not set any measurable outcome-oriented targets:

a. you may disclose whether such targets will be set and the timeframe for setting them, or the reasons why you do not plan to set such targets

b. you shall disclose whether you nevertheless track the effectiveness of your policies and actions in relation to the material sustainability-related impact, risk and opportunity and if so:

i. any processes through which you do so

ii. the defined level of ambition to be achieved and any qualitative or quantitative indicators you use to evaluate progress, including the base period from which progress is measured

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This disclosure shall include the total energy consumption in MWh related to your own operations disaggregated by:

a. total energy consumption from fossil sources

b. total energy consumption from nuclear sources

c. total energy consumption from renewable sources disaggregated by

i. fuel consumption for renewable sources including biomass (also comprising industrial and municipal waste of biologic origin), biofuels, biogas, hydrogen from renewable sources

ii. consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources

iii. consumption of self-generated non-fuel renewable energy

If you have operations in high climate impact sectors you shall further disaggregate your total energy consumption from fossil sources by:

a. fuel consumption from coal and coal products

b. fuel consumption from crude oil and petroleum products

c. fuel consumption from natural gas

d. fuel consumption from other fossil sources

e. consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources

Additionally, you shall disaggregate and disclose separately your non-renewable energy production and renewable energy production in MWh, where applicable.

Moreover, you shall provide information on your energy intensity (total energy consumption per net revenue) associated with activities in high climate impact sectors.

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Your disclosure on gross Scope 1 GHG emissions shall include:

a. the gross Scope 1 GHG emissions in metric tonnes of CO2eq

b. the percentage of Scope 1 GHG emissions from regulated emission trading schemes

Your disclosure on gross Scope 2 GHG emissions shall include:

a. the gross location-based Scope 2 GHG emissions in metric tonnes of CO2eq

b. the gross market-based Scope 2 GHG emissions in metric tonnes of CO2eq

For Scope 1 and Scope 2 emissions you shall disaggregate the information and separately disclosing emissions from:

a. the consolidated accounting group (the parent and subsidiaries)

b. investees such as associates, joint ventures, or unconsolidated subsidiaries that are not fully consolidated in the financial statements of the consolidated accounting group, as well as contractual arrangements that are joint arrangements not structured through an entity (i.e., jointly controlled operations and assets), for which you have operational control

Your disclosure of gross Scope 3 GHG emissions shall include GHG emissions in metric tonnes of CO2eq from each significant Scope 3 category (i.e. each Scope 3 category that is a priority for your organization).

Your disclosure of total GHG emissions shall be the sum of your Scope 1, 2 and 3 GHG emissions. Your total GHG emissions shall be disclosed with a disaggregation that makes a distinction of:

a. the total GHG emissions derived from the underlying Scope 2 GHG emissions being measured using the location-based method

b. the total GHG emissions derived from the underlying Scope 2 GHG emissions being measured using the market-based method

Furthermore, you shall disclose your GHG emissions intensity (total GHG emissions per net revenue).

Your disclosure on GHG intensity shall provide your total GHG emissions in metric tonnes of CO2eq per net revenue.

Lastly, you shall disclose the relevant line item or notes in your financial statements of your net revenue amounts (the denominator in the calculation of the GHG emissions intensity).

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Your disclosure on GHG removals and storage shall include, if applicable:

a. the total amount of GHG removals and storage in metric tonnes of CO2eq disaggregated and separately disclosed for:

i. the amount related to your own operations

ii. the amount related to your upstream and downstream value chain, broken down by removal activity

b. the calculation assumptions, methodologies and frameworks you have applied

Your disclosure on carbon credits shall include, if applicable:

a. the total amount of carbon credits outside your value chain in metric tonnes of CO2eq that are verified against recognised quality standards and cancelled in the reporting period

b. the total amount of carbon credits outside your value chain in metric tonnes of CO2eq planned to be cancelled in the future and whether they are based on existing contractual agreements or not

In the case you disclose a net-zero target in addition to your gross GHG emission reduction targets you shall explain the scope, methodologies and frameworks applied and how your residual GHG emissions are intended to be neutralised by, for example, GHG removals in your own operations and your upstream and donwstream value chain.

In case you have made public claims of GHG neutrality that involve the use of carbon credits, you shall explain:

a. whether and how these claims are accompanied by your GHG emission reduction targets

b. whether and how these claims and the reliance on carbon credits neither impede nor reduce the achievement of your GHG emission reduction targets, or, if applicable, your net zero target 

c. the credibility and integrity of the carbon credits you have used, including by reference to recognised quality standards

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The following information is required by this disclosure requirement:

a. the type of internal carbon pricing scheme, for example, the shadow prices applied for CapEX or research and development (R&D) investment decision making, internal carbon fees or internal carbon funds

b. the specific scope of application of the carbon pricing schemes (activities, geographies, entities, etc.)

c. the carbon prices applied according to the type of scheme and critical assumptions made to determine the prices, including the source of the applied carbon prices and why these are deemed relevant for their chosen application. You may also disclose your calculation methodology of the carbon prices including the extent to which these have been set using scientific guidance and how their future development is related to science-based carbon pricing trajectories

d. your approximate gross GHG emission volumes by Scopes 1 and 2 in the current year, and where applicable, Scope 3 in metric tonnes of CO2eq covered by these schemes, as well as their share of your overall GHG emissions for each respective Scope

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The disclosure of anticipated financial effects from material physical risks shall include:

a. the monetary amount and proportion (percentage) of assets at material physical risk over the short-, medium- and long-term before considering climate change adaptation actions, with the monetary amounts of these assets disaggregated by acute and chronic physical risk

b. the proportion of assets at material physical risk addressed byclimate change adaptation actions

c. the location of significant assets at material physical risk

d. the monetary amount and proportion (percentage) of net revenue from your business activities at material physical risk over the short-, medium- and long-term

The disclosure of anticipated financial effects from material transition risks shall include:

a. the monetary amount and proportion (percentage) of assets at material transition risk over the short-, medium- and long-term before considering climate mitigation actions

b. the proportion of assets at material transition risk addressed by the climate change mitigation actions

c. a breakdown of the carrying value of your organization’s real estate assets by energy efficiency classes

d. liabilities that may have to be recognised in financial statements over the short-, medium- and long-term

e. the monetary amount and proportion (percentage) of net revenue from your business activities at material transition risk over the short-, medium- and long-term including the net revenue from your customers operating in coal, oil and gas-related activities, if relevant

You shall also disclose reconciliations to the relevant line items or notes in your financial statements of the following:

a. significant amounts of your assets and net revenue at material physical risk

b. significant amounts of your assets, liabilities, and net revenue at material transition risk

For the disclosure of the potential to pursue climate-related opportunities your shall consider:

a. your expected cost savings from climate change mitigation and adaptation actions

b. the potential market size or expected changes to net revenue from low-carbon products and services or adaptation solutions to which your organization have or may have access

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Specifically, your disclosure regarding policies related to pollution should include the following:

a. How you mitigate negative impacts related to pollution of air, water and soil, including the prevention and control of these

b. How you substitute and minimise the use of substances of concern

c. How you phase out substances of very high concern, in particular for non-essential societal use and in consumer product

d. How you avoid incidents and emergency situations, and if and when they occur, how you control and limit their impact on people and the environment

These issues should be addressed both in regard to your own operations and your upstream and downstream value chain, when material.

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information:

a. a description of the key contents of your policy related to pollution, including its general objectives and which material impacts, risks or opportunities the policy relates to and the process for monitoring

b. a description of the scope of the policy, or of its exclusions, in terms of activities, upstream and/or downstream value chain, geographies and if relevant, affected stakeholder groups

c. the most senior level in your organisation that is accountable for the implementation of the policy

d. a reference, if relevant, to the third-party standards or initiatives your organization commit to respect through the implementation of the policy

e. if relevant, a description of the consideration given to the interests of key stakeholders in setting the policy

f. if relevant, whether and how you make the policy available to potentially affected stakeholders, and stakeholders who need to help implement it

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Specifically, in this disclosure you may specify to which layer in the following mitigation hierarchy an action and resources can be allocated:

a. avoid pollution, including any phase out of materials or compounds that have a negative impact (prevention of pollution at source)

b. reduce pollution, including: 

i. any phase-out of materials or compounds

ii. meeting enforcement requirements such as Best Available Techniques (BAT) requirements

iii. meeting the Do No Significant Harm criteria for pollution prevention and control according to the EU Taxonomy Regulation and its Delegated Acts (minimisation of pollution)

c. restore, regenerate and transform ecosystems where pollution has occurred (control of the impacts both from regular activities and incidents)

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information:

a. the list of key actions taken in the reporting year and planned for the future, their expected outcomes and, where relevant, how their implementation contributes to the achievement of policy objectives and targets

b. the scope of the key actions (i.e., coverage in terms of activities, upstream and/or downstream value chain, geographies and, where applicable, affected stakeholder groups)

c. the time horizons under which you intend to complete each key action

d. if applicable, key actions taken (along with results) to provide for and cooperate in or support the provision of remedy for those harmed by actual material impacts

e. if applicable, quantitative and qualitative information regarding the progress of actions or action plans disclosed in prior periods

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Specifically, pollution-related targets should indicate whether and how they relate to the prevention and control of: 

a. air pollutants and respective specific loads

b. emissions to water and respective specific loads

c. pollution to soil and respective specific loads

d. substances of concern and substances of very high concern

You may specify whether ecological thresholds (e.g., the biosphere integrity, stratospheric ozone-depletion, atmospheric aerosol loading, soil depletion, ocean acidification) and entity-specific allocations were taken into consideration when setting your targets. If so, you may specify:

a. the ecological thresholds identified, and the methodology used to identify such thresholds

b. whether or not the thresholds are entity-specific and if so, how they were determined

c. how responsibility for respecting identified ecological thresholds is allocated in your organization

You shall also specify as part of the contextual information, whether the targets you have set and presented are mandatory (required by legislation) or voluntary.

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information for each measurable, outcome-oriented and time-bound target on material sustainability matters that you have set:

a. a description of the relationship of the target to the policy objectives 

b. the defined target level to be achieved, including, where applicable, whether the target is absolute or relative and in which unit it is measured

c. the scope of the target, including your own activities and/or your upstream and/or downstream value chain where applicable and geographical boundaries

d. the baseline value and base year from which progress is measured

e. the period to which the target applies and if applicable, any milestones or interim targets

f. the methodologies and significant assumptions used to define targets, including where applicable, the selected scenario, data sources, alignment with national, EU or international policy goals and how the targets consider the wider context of sustainable development and/or local situation in which impacts take place

g. whether your targets related to environmental matters are based on conclusive scientific evidence

h. whether and how stakeholders have been involved in target setting for each material sustainability matter

i. any changes in targets and corresponding metrics or underlying measurement methodologies, significant assumptions, limitations, sources and processes to collect data adopted within the defined time horizon. This includes an explanation of the rationale for those changes and their effect on comparability

j. the performance against your disclosed targets, including information on how the target is monitored and reviewed and the metrics used, whether the progress is in line with what had been initially planned, and an analysis of trends or significant changes in the performance of your organization towards achieving the target

If you have not set any measurable outcome-oriented targets:

a. you may disclose whether such targets will be set and the timeframe for setting them, or the reasons why you do not plan to set such targets

b. you shall disclose whether you nevertheless track the effectiveness of your policies and actions in relation to the material sustainability-related impact, risk and opportunity and if so:

i. any processes through which you do so

ii. the defined level of ambition to be achieved and any qualitative or quantitative indicators you use to evaluate progress, including the base period from which progress is measured

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You shall disclose the amounts of:

a. each pollutant listed in Annex II of Regulation (EC) No 166/2006 of the European Parliament and of the Council64 (European Pollutant Release and Transfer Register “EPRTR Regulation”) emitted to air, water and soil, with the exception of emissions of GHGs which are disclosed in accordance with ESRS E1 Climate Change

b. microplastics generated or used by your organization

These amounts shall be consolidated amounts including the emissions from those facilities over which you have financial control and those over which you have operational control. The consolidation shall include only the emissions from facilities for which the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded. 

Furthermore, you shall put your disclosure into context and describe:

a. the changes over time

b. the measurement methodologies

c. the process(es) to collect data for pollution-related accounting and reporting, including the type of data needed and the information sources

Lastly, when you choose an inferior methodology compared to direct measurement of emissions quantify emissions, you shall outline the reasons for choosing this inferior methodology. If you use estimates, you shall disclose the standard, sectoral study or sources which form the basis of your estimates, as well as the possible degree of uncertainty and the range of estimates reflecting the measurement uncertainty.

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This disclosure requirement shall include the total amounts of substances of concern that are generated or used during the production or that are procured, and the total amounts of substances of concern that leave your facilities as emissions, as products, or as part of products or services split into main hazard classes of substances of concern. You shall present the information for substances of very high concern separately.

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This disclosure shall include:

a. a quantification of the anticipated financial effects in monetary terms before considering pollution-related actions, or where not possible without undue cost or effort, qualitative information. For financial effects arising from opportunities, a quantification is not required if it would result in a disclosure that does not meet the qualitative characteristics of information

b. a description of the effects considered, the related impacts and the time horizons in which they are likely to materialise

c. the critical assumptions used to quantify the anticipated financial effects, as well as the sources and level of uncertainty of those assumptions

Furthermore, the following information shall be disclosed:

a. the share of net revenue made with products and services that are or that contain substances of concern, and the share of net revenue made with products and services that are or that contain substances of very high concern

b. the operating and capital expenditures incurred in the reporting period in conjunction with major incidents and deposits

c. the provisions for environmental protection and remediation costs, e.g., for rehabilitating contaminated sites, recultivating landfills, removal of environmental contamination at existing production or storage sites and similar measures

You shall also disclose any relevant contextual information including a description of material incidents and deposits whereby pollution had negative impacts on the environment and/or is expected to have negative effects on your financial cash flows, financial position and financial performance with short-, medium- and long-term time horizons.

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Policies related to water and marine resources should indicate the following, when material:

a. your water management, including:

i. the use and sourcing of water and marine resources in your own operations

ii. water treatment as a step towards more sustainable sourcing of water

iii. the prevention and abatement of water pollution resulting from your activities

b. your product and service design in view of addressing water-related issues and the preservation of marine resources

c. your commitment to reduce material water consumption in areas at water risk in your own operations and along your upstream and downstream value chain

If at least one of your sites is located in an area of high-water stress and it is not covered by a policy, you shall state this to be the case and provide reasons for not having adopted such a policy. You may also disclose a timeframe in which you aim to adopt such a policy.

You shall also specify whether you have adopted policies or practices related to sustainable oceans and seas.

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information:

a. a description of the key contents of your policy related to water and marine resources, including its general objectives and which material impacts, risks or opportunities the policy relates to and the process for monitoring

b. a description of the scope of the policy, or of its exclusions, in terms of activities, upstream and/or downstream value chain, geographies and if relevant, affected stakeholder groups

c. the most senior level in your organisation that is accountable for the implementation of the policy

d. a reference, if relevant, to the third-party standards or initiatives your organization commit to respect through the implementation of the policy

e. if relevant, a description of the consideration given to the interests of key stakeholders in setting the policy

f. if relevant, whether and how you make the policy available to potentially affected stakeholders, and stakeholders who need to help implement it

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Specifically, resources can for example be allocated to:

a. avoiding the use of water and marine resources

b. reducing the use of water and marine resources through efficiency measures

c. reclaiming and reuse of water

d. restoration and regeneration of aquatic ecosystem and water bodies

Furthermore, you shall specify actions and resources in relation to areas at water risk, including areas of high-water stress.

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information:

a. the list of key actions taken in the reporting year and planned for the future, their expected outcomes and, where relevant, how their implementation contributes to the achievement of policy objectives and targets

b. the scope of the key actions (i.e., coverage in terms of activities, upstream and/or downstream value chain, geographies and, where applicable, affected stakeholder groups)

c. the time horizons under which you intend to complete each key action

d. if applicable, key actions taken (along with results) to provide for and cooperate in or support the provision of remedy for those harmed by actual material impacts

e. if applicable, quantitative and qualitative information regarding the progress of actions or action plans disclosed in prior periods

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Targets related to water and marine resources should relate to: 

a. the management of impacts, risks and opportunities related to areas at water risk, including improvement of the water quality

b. the responsible management of marine resources impacts, risks and opportunities including the nature and quantity of marine resources-related commodities (such as gravels, deep-sea minerals, seafood) used by your organization

c. the reduction of water consumption, including an explanation of how those targets relate to areas at water risk, including areas of high water-stress

You may specify whether ecological thresholds and entity-specific allocations were taken into consideration when setting your targets. If so, you may specify:

a. the ecological thresholds identified, and the methodology used to identify such thresholds

b. whether or not the thresholds are entity-specific and if so, how they were determined

c. how responsibility for respecting identified ecological thresholds is allocated in your organization

You shall also specify as part of the contextual information, whether the targets you have set and presented are mandatory (required by legislation) or voluntary.

In addition to this, according to the general minimum requirements for this disclosure requirement you need to provide the following information for each measurable, outcome-oriented and time-bound target on material sustainability matters that you have set:

a. a description of the relationship of the target to the policy objectives 

b. the defined target level to be achieved, including, where applicable, whether the target is absolute or relative and in which unit it is measured

c. the scope of the target, including your own activities and/or your upstream and/or downstream value chain where applicable and geographical boundaries

d. the baseline value and base year from which progress is measured

e. the period to which the target applies and if applicable, any milestones or interim targets

f. the methodologies and significant assumptions used to define targets, including where applicable, the selected scenario, data sources, alignment with national, EU or international policy goals and how the targets consider the wider context of sustainable development and/or local situation in which impacts take place

g. whether your targets related to environmental matters are based on conclusive scientific evidence

h. whether and how stakeholders have been involved in target setting for each material sustainability matter

i. any changes in targets and corresponding metrics or underlying measurement methodologies, significant assumptions, limitations, sources and processes to collect data adopted within the defined time horizon. This includes an explanation of the rationale for those changes and their effect on comparability

j. the performance against your disclosed targets, including information on how the target is monitored and reviewed and the metrics used, whether the progress is in line with what had been initially planned, and an analysis of trends or significant changes in the performance of your organization towards achieving the target

If you have not set any measurable outcome-oriented targets:

a. you may disclose whether such targets will be set and the timeframe for setting them, or the reasons why you do not plan to set such targets

b. you shall disclose whether you nevertheless track the effectiveness of your policies and actions in relation to the material sustainability-related impact, risk and opportunity and if so:

i. any processes through which you do so

ii. the defined level of ambition to be achieved and any qualitative or quantitative indicators you use to evaluate progress, including the base period from which progress is measured

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The disclosure should include:

a. total water consumption in m3

b. total water consumption in m3 in areas at water risk, including areas of high-water stress

c. total water recycled and reused in m3

d. total water stored and changes in storage in m3

e. any contextual information necessary regarding points (a) to (d), including the water basins’ water quality and quantity, how the data have been compiled, such as any standards, methodologies, and assumptions used, including whether the information is calculated, estimated, modelled, or sourced from direct measurements, and your approach taken for this, such as the use of any sector-specific factors

You also need to disclose information about your water intensity; your total water consumption in your own operations in m3 per million EUR net revenue.

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This disclosure shall include:

a. a quantification of the anticipated financial effects in monetary terms before considering water and marine resources-related actions or where not possible without undue cost or effort, qualitative information. For financial effects arising from opportunities, a quantification is not required if it would result in disclosure that does not meet the qualitative characteristics of information

b. a description of the effects considered, the impacts and dependencies to which they relate, and the time horizons in which they are likely to materialise

c. the critical assumptions used to quantify the anticipated financial effects, as well as the sources and level of uncertainty of those assumptions

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